Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 1 of 28
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on May 15, 2009
UNITED STATES OF AMERICA,
Plaintiff, CRIMINAL NO. 08-057 v.
ANTONIO EZEQUIEL VIOLATIONS: CARDENAS-GUILLEN, (1) a.ka. "Tony Tormenta"; 21 U.S.C. §§ 959, 960, 963 (Conspiracy to Manufacture and JORGE EDUARDO Distribute Five Kilograms or COSTILLA-SANCHEZ, (2) More of Cocaine and 1000 Kilograms
a.k.a. "El Cos," a.k.a "Doble X," or More of Marijuana for Importation a.k.a. "Dos Equis"; into the United States)
HERIBERTO LAZCANO-LAZCANO, (3) a.k.a. "Lazca," a.k.a. "EI Licenciado"; 21 U.S.C. § 959
(Distribution of Five Kilograms or MIGUEL TREVINO MORALES, (4) More of Cocaine for Importation a.k.a. "40," a.l(.a. "Zeta 40," into the United States) a.k.a. "Cuarenta";
JAIME GONZALEZ-DURAN, (5) a.k.a. "Hummer"; 18 U.S.C. § 2 (Aiding and Abetting) SAMUEL FLORES BORRGO, (6) a.k.a. "Tres," a.ka. "Metro Tres"; 21 U.S.C. § 853 21 U.S.C. § 970
MARIO RAMIREZ- TREVIÑO, (7) (F orfeiture) a.ka. "Mario Pelon," a.ka. "X-20"; Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 2 of 28
ALFREDO RANGEL BUENDIA, (8) a.ka. "Chicles";
FIRST NAME UNKNOWN, LAST NAME UNKNOWN, (9) a.k.a. "Lino";
GILBERTO BARRGAN-BALDERAS, (10) a.ka. "Tòcayo;"
JUAN REYES MEJIA-GONZALEZ, (11) a.k a. "R -1," a.k. a. "Kike," a.k.a. "Reyes";
OMAR TREVINO MORALES, (12) a.ka. "42";
JESUS ENRIQUE REJON AGUILAR, (13) a.k.a. "Mamito," a.ka. "Cabellero;
ALFONSO LAM-LIU, (14) a.k.a. "Gordo Lam";
ELEAZAR MEDINA ROJAS, (15) a.k.a. "EI Chelelo";
AURELIO CANO-FLORES, (16) a.k.a. "Yankee," a.k.a. "Yeyo";
CARLOS CERDA-GONZALEZ, (17) a.k.a. "Puma," a.k.a. "Carlitos";
VICTOR HUGO LOPEZ-VALDEZ, (18) : a.ka. "Jorge Hernandez-Martinez," a.k.a. "Chiri," a.k.a. "Chiriquas";
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SIGIFREDO NAJERA- TALAMANTES, (19) a.k.a. "Canicon," a.k.a. "Chito," a.k.a. "Chito Can," a.k.a. "Chito Canico," a.k.a. "Chito Canicon";
DANIEL PEREZ-ROJAS, (20) a.k.a. "Cachetes" a.k.a. "Cacheton" Defendants.
SECOND SUPERSEDING INDICTMENT
THE GRAND JURY CHARGES THAT:
COUNT I CONSPIRACY TO MANUFACTURE AND DISTRIBUTE COCAINE AND MARIJUANA FOR IMPORTATION INTO THE UNITED STATES
THE CONSPIRACY 1 . From in or about June 2006 and continuing thereafter up to and including the date
of the fiing of this Second Superseding Indictment, the exact dates being unknown to the Grand
Jury, in the countries of Mexico, Colombia, Guatemala, Panama, and elsewhere, defendants,
ANTONIO EZEQUIEL CARDENAS-GUILLEN, a.k.a. "Tony Tonnenta," ("CARDENAS-
GUILLEN"); JORGE EDUARDO COSTILLA-SANCHEZ, a.k.a. "El Cos," a.k.a. "Doble X," a.k.a. "Dos Equis" ("COSTILLA"); HERIBERTO LAZCANO-LAZCANO, a.k.a. "Lazca," a.k.a. "El Licenciado" ("LAZCANO"); MIGUEL TREVINO MORALES, a.lca. "40," a.k.a.
"Zeta 40," a.k.a. "Cuarenta" ("MIGUEL TREVINO MORALES"); JAIME GONZALEZ-
DURAN, a.k.a. "Hummer" ("GONZALEZ-DURAN"); SAMUEL FLORES BORREGO, a.k.a.
"Tres," a.k.a. "Metro Tres" ("FLORES BORRGO"); MARIO RAMIREZ-TREVINO, a.lea.
"Mario Pelon," a.k.a. "X-20" ("RAMIREZ-TREVINO"); ALFREDO RANGEL BUENDIA,
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a.k.a. "Chicles" ("RANGEL"); FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. "Lino" ("LINO"); GILBERTO BARRGAN-BALDERAS, a.lea. "Tocayo"
("BARRAGAN-BALDERAS"); JUAN REYES MEJIA-GONZALEZ, a.k.a. "R-l," a.lea.
"Kike," a.k.a. "Reyes" (MEJIA-GONZALEZ"); OMAR TREVINO MORALES, a.k.a. "42,"
("OMAR TREVINO MORALES"); JESUS ENRIQUE REJON AGUILAR, a.k.a. "Mamito,"
a.k.a. "Cabellero" ("REJON AGUILAR"); ALFONSO LAM-LIU, a.k.a. "Gordo Lam" ("LAM-
LIU"); ELEAZAR MEDINA ROJAS, a.k.a. "El Chelelo" ("MEDINA ROJAS"); AURELIO
CANO-FLORES, a.k.a. "Yankee," a.lea. "Yeyo" ("CANO-FLORES"); CARLOS CERDA-
GONZALEZ, a.k.a. "Puma," a.k.a. "Carlitos" ("CERDA-GONZALEZ"); VICTOR HUGO
LOPEZ-VALDEZ, a.k.a. "Jorge Hernandez-Maiiiiiez,"a.k.a. "Chiri," a.k.a. "Chiriquas"
("LOPEZ-VALDEZ"); SIGIFREDO NAJERA-TALAMANTES, a.k.a. "Canicon," a.k.a.
"Chito,"a.k.a. "Chito Can," a.k.a. "Chito Canico," a.k.a. "Chito Canicon" ("NAJERA-
TALAMANTES"); DANIEL PEREZ-ROJAS, a.k.a. "Cachetes," a.k.a. "Cacheton" ("PEREZ-
ROJAS") and others unknown to the Grand Jury and not indicted herein, did knowingly and iiitcntionally combine, conspire, confederate, and agree to commit the following offense against the United States of America: (l) to knowingly and intentionally manufacture and/or distribute five kilograms or more of a mixture and substance containing a detectable amount of cocaine, a
Schedule II controlled substance, knowing and intending that such substance would be imported into the United States from Mexico, and (2) to knowingly and intentionally manufacture and/or distribute 1000 kilograms or more of a mixture and substance containing a detectable amount of marijuana, a Schedule I controlled substance, knowing and intending that such substance would be imported into the United States from Mexico; all in violation of Title 21, United States Code,
Sections 959, 960,963, and Title 18, United States Code, Section 2.
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OBJECT OF THE CONSPIRACY
2. It was the object of the conspiracy to acquire, sell, and distribute cocaine and marijuana and to transport such cocaine and marijuana out of Mexico and import it into the
United States.
MANNER AND MEANS OF THE CONSPIRACY
3. For all periods of time relevant to the charges contained in this Superseding
Indictment, the defendants and other co-conspirators, both lmown and unlmown to the Grand
Jury, used the following maimer and means to accomplish the goals of the conspiracy:
A. The defendants were members of either one of two Mexican-based
narcotics trafficking organizations, the "Gulf Coast Cartel" and "Los Zetas," which
organizations operated together under the name of "The Company," (hereinafter referred
to as "The Company").
B. The Company was led primarily by a governing council or "triumvirate"
composed of three ofthe defendants, CARDENAS-GUILLEN, COSTILLA, and
LAZCANO.
C. The Company controlled hundreds of miles of Mexican territory along the
border of Mexico and the United States, including the border of Mexico and Texas.
D. The Company divided its tenitory into areas known as "plazas" along the
Mexico-United States border and assigned each plaza region a leader known as a "plaza
boss."
E. CARDENAS-GUILLEN, COSTILLA, and LAZCANO directed the
traiispoiiation of The Company's cocaine and marijuana shipments via boats, planes, and
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automobiles from Colombia and Venezuela to Guatemala, and to various cities and
"plazas" in Mexico.
F. Under the direction of CARDENAS-GUILLEN, COSTILLA, and
LAZCANO, The Company transported shipments of cocaine and marijuana by means of
motor vehicles from Mexico to cities iii Texas for distribution to other cities within the
United States.
G. The defendants, along with other members of The Company, organized,
directed, and carried out various acts of violence against Mexican law enforcement
officers and rival drug traffickers to retaliate against and to intimidate any individual or
individuals who interfered with or who were perceived to potentially interfere with the
cocaine and marijuana trafficking activities of The Company.
H. The defendants and other members of the The Company utilzed N extel
"push-to-talk" telephones and UHF/VHF radio communications to coordinate shipments
of cocaine and marijuana and to evade law enforcement surveilance.
1. The defendants and other members of the The Company utilized
sophisticated record keeping programs by means of laptop computers and "flashdrive" memory-storage devices, which maintained a comprehensive database that included records of cocaine shipment amounts, plaza boss identities and plaza locations, payroll amounts, payments made to law enforcement officials, and money received and owed.
1. The defendants and other members of the The Company often spoke in coded language during telephone eonversatioiis to disguise and conceal the nature of their cocaiiie and marijuana trafficking activities.
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K. The individual roles performed within The Company organization by each
of the defendants were as follows:
1. ANTONIO EZEQUIEL CARDENAS-GUILLEN, a. k. a. "Tony
Tormenta." CARDENAS-GUILLEN was one of the three leaders of the The
Company. CARDENAS-GUILLEN was actively involved in managing the
activities of The Company in Mexico, including the coordination of cocaine and
marijuana shipments into the United States, as well as the receipt of bulk currency
shipments into Mexico from the United States.
2. JORGE EDUARDO COSTILLA-SANCHEZ, a.k.a. "El Cos, "
a.k.a. "Doble.Y" a.k.a. "Dos Equis." COSTILLA was one of the three leaders
of The Company. COSTILLA was actively involved in managing the activities
of the Gulf Cartel in Mexico, including the coordination of cocaine and marijuana
shipments into the United States, as well as the receipt of bulk currency shipments
into Mexico from the United States.
3. HERIBERTO LAZCANO-LAZCANO, a.k.a. "LazcCf," a.k.a.
"El Licenciado." LAZCANO was one of three leaders of The Company.
LAZCANO was the leader of Los Zetas and the security chief for the Gulf Cartel.
LAZCANO was actively involved in managing the activities of the Gulf Caiiel
and the Los Zetas in Mexico, including the coordination of cocaine and marijuana
shipments into the United States, as well as the receipt of bulk currency shipments
into Mexico from the United States.
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4. MIGUEL TREVINO MORALES, a.ka, "40, /I a.ka. "Zeta 40, ":
a,ka. "Cuarenta," MIGUEL TREVINO MORALES was a ranking member of
the Los Zetas and was recognized as the second in command of the Los Zetas.
MIGUEL TREVINO MORALES was actively involved in managing the
activities of the Gulf Cartel and the Los Zetas in Mexico, including the
coordination of cocaine and marijuana shipments into the United States, as well as
the receipt of bulk currency shipments into Mexico from the United States.
MIGUEL TREVINO MORALES oversaw and supervised activities of The
Company in certain areas in Mexico near the United States border, including those
areas in and around Veracruz and Nuevo Laredo, Mexico.
5, JAIME GONZALEZ-DURAN, a.k.a. "Hummer." GONZALEZ-
DURAN was an original member of the Los Zetas and served as a regional
commander of the Los Zetas. In this position, GONZALEZ-DURAN oversaw
and supervised activities of The Company in ceiiain areas in Mexico near the
United States border, including those areas in and around Nuevo Laredo, Miguel
Aleman, and Reynosa, Mexico. GONZALEZ-DURAN was actively involved iii
the coordination of cocaine and marijuana shipments into the United States, as
well as the receipt of bulk currency shipments into Mexico from the United States.
6. SAMUEL FLORES BORREGO, a.ka. "Tres," a.ka, "Metro
Tres." FLORES BORRGO was a ranlcing member of the Gulf Caiiel and was
in control of The Company's operations in and around Reynosa and Miguel
Aleman, Mexico. FLORES BORRGO obtained and provided information to
members of The Company regarding ceiiain law enforcement operations directed
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against The Company. FLORES BORREGO was actively involved in managing
the activities of The Company in Mexico, including the coordination of cocaine
and marijuana shipments into the United States, as well as the receipt of bulk
currency shipments into Mexico from the United States.
7. MARIO RAMIREZ-TREVINO, a.ka. "Mario Pelon, " a.ka.
"X-20." RAMIREZ-TREVINO was a ranlcing member of the Gulf Cartel and
was the second in command for the Gulf Cartel in and around Reynosa, Mexico.
RAMlREZ- TREVINO was actively involved in managing the activities of The
Company in Mexico, including the coordination of cocaine and marijuana
shipments into the United States, as well as the receipt of bulk currency shipments
into Mexico from the United States.
8, ALFREDO RANGEL BUENDIA, a.ka. "Chicles." RANGEL
was a member of the Los Zetas who oversaw and assisted in the supervision of
The Company's activities in and around Miguel Aleman, Mexico. RANGEL was
actively involved in managing the activities of The Company in Mexico,
including the coordiiiatioii of cocaine and marijuana shipments into the United
States, as well as the receipt of bulk currency shipments into Mexico from the
United States.
9. FIRST NAME UNKNOWN LAST NAME UNKNOWN a.ka.
"Lino. "("LINO"). LINO was a Gulf Cartel member and recognized as one of
the primary accountants for The Company. LINO was involved in the receipt of
bulk currency shipments from the United States to Nuevo Laredo, Mexico.
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10. GILBERTO BARRGAN-BALDERAS, a.ka. "Tocayo."
BARRGAN-BALDERAS was actively involved in managing the activities of
The Company in Mexico, including the coordination of cocaine shipments into the
United States, as well as the receipt of bulk currency shipments into Mexico from
the United States. BARRGAN-BALDERAS obtained and provided
information to members of The Company regarding law enforcement operations
directed against "The Company."
11. JUAN REYES MEJIA-GONZALEZ, a.ka. "R-l, JJ a.ka. "Kike,"
a. k a. "Reyes." MEJIA-GONZALEZ was a member of the Gulf Cartel who
facilitated and assisted the purchase of cocaine by The Company from sources of
supply located in Central and South America. MEJIA-GONZALEZ was
actively involved in managing the activities of The Company in Mexico,
including the coordination of cocaine and marijuana shipments into the United
States, as well as the receipt of bulk currency shipments into Mexico from the
United States.
12. OMAR TREVINO MORALES, a.ka. "42." OMAR TREVINO
MORALES had a leadership role and oversaw The Company's activities in
Coahuila, Mexico. OMAR TREV:INO MORALES was actively involved in
managing the activities of The Company in Mexico, including the coordination of
cocaine and marijuana shipments into the United States, as well as the receipt of
bulk CUl1ency shipments into Mexico from the United States.
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13. JESUS ENRIQUE REJON AGUILAR, a.ka. "Mamito, " a,ka.
"Cabellero." REJON AGUILAR was an original member of the Los Zetas.
Along with OMAR TREVINO MORALES, REJON AGUILAR oversaw The
Company's activities in the Mexican state of Coahuila. REJON AGUILAR was
actively involved in managing the activities of The Company in Mexico,
including the coordination of cocaine and marijuana shipments into the United
States.
14. ALFONSO LAM-LIU, a.ka. "Gordo Lam." LAM-LIU was a
member of the Gulf Caiiel. LAM-LIU was the plaza boss of Rio Bravo, Mexico.
LAM-LIU was actively involved in managing the activities of The Company in
Mexico, including the coordination of cocaine and marijuana shipments into the
United States, as well as the receipt of bulk currency shipments into Mexico from
the United States.
15. ELEAZAR MEDINA ROJAS, a.ka. "El Chelelo." MEDINA
ROJAS was member of the Los Zetas who oversaw The Company's activities in
and around Monteney, Mexico. MEDINA ROJAS was actively involved in
managing the activities of The Company in Mexico, including the coordination of
cocaine and marijuana shipments into the United States.
16. AURELIO CANO-FLORES, a.k.a. "Yankee," a.ka. "Yeyo."
CANO-FLORES oversaw The Company's activities in Camargo, Mexico, and
was involved in the procurement of bulk quaiitities ~f cocaine and heroin for The
Company. CANO-FLORES was actively involved in managing the activities of
The Company in Mexico, including the coordination of cocaine and marijuana
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shipments into the United States, as well as the receipt of bulk currency shipments
into Mexico from the United States.
17. CARLOS CERDA-GONZALEZ, a,ka. "Puma," a.ka.
"Carlitos." CERDA-GONZALEZ was actively involved in The Company's
activities in thc Tampico, Mexico, including the procurement of
multiple-thousand kilogram shipments of cocaine. CERDA-GONZALEZ was
actively involved in managing the activities of The Company in Mexico,
including the coordination of cocaine and marijuana shipments into the United
States, as well as the receipt of bulk currency shipments into Mexico from the
United States.
18. VICTOR HUGO LOPEZ-VALDEZ, a.ka. "Jorge Hernandez-
Jvlartinez, "a,ka. "Chiri," a.ka. "Chiriquas." LOPEZ-VALDEZ worked for
LAZCANO. LOPEZ-VALDEZ handled personal and business matters for
LAZCANO related to The Company's activities, including placing and receiving
telephone calls to other members of The Company to assist in the coordination of
cocaIne and marij uana shipments from Mexico into the United States, as well as
the receipt of bulk currency shipments into Mexico from the United States.
19. SIGIFREDO NAJERA-TALAMANTES, a.ka. "Canicon," a.ka.
"Chito, "a.ka. "Chito Can, "a.ka. "Chito Canico, "a.ka, "Chito Canicon. "
NAJERA-TALAMANTES was a member of the Los Zetas served as the plaza
boss in and around Monterrey, Mexico. NAJERA-TALAMANTES was actively
involved in managing the activities of The Company in Mexico, including the
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coordination of cocaine and marijuana shipments into the United States, as well as
the receipt of bulk currency shipments into Mexico from the United States.
20. DANIEL PEREZ-ROJAS, a.ka. "Cachetes," a.ka. "Cacheton."
PEREZ-ROJAS was a member of the Los Zetas operating in Rio Bravo, San
Luis Potosi, Valle Hermoso, Tampico and Veracruz, Mexico. PEREZ-ROJAS
was in charge of maintaining communications systems utilized by LAZCANO.
Additionally, PEREZ-ROJAS received and carried out orders from LAZCANO
by giving orders to his subordinates as well as passing along LAZCANO's
instruction, information, and orders to others in The Company.
OVERT ACTS
4. In fuiiherance of the conspiracy and to effect the objects thereof, the defendants, along with other co-conspirators both known and unknown to the Grand Jury, within Mexico the following overt acts ("OA#") were committed, among others:
OAL. On or about June 5, 2006, NAJERA-TALAMANTES purchased
fifteen kilograms of cocaine from The Company, at a price of $13,500 per kilogram, for a
total purchase price of $202,500.00.
OA2. On or about June 23, 2006, NAJERA-TALAMANTES purchased
ten kilograms of cocaine from The Company, at a price of $13,500 per kilogram, for a
total purchase price of$135,000.00.
OA3. On or about July 20, 2006, NAJERA-TALAMANTES purchased
twenty kilograms of cocaine from The Company, at a price of $ 1 3,500 per kilogram, for a
total purchase price of $270,000.00.
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OA4. On or about August 17,2006, NAJERA-TALAMANTES purchased twenty kilograms of cocaine from The Company, at a price of $13,500 per kilogram, for a total purchase price of $270,000.00.
OA5. In a telephone conversation on or about October 21,2006,
MIGUEL TREVINO MORAES told GONZALEZ-DURAN that bonuses are paid according to the plaza in which the members work, that bonuses are paid according to seniority, and that bosses receive bonuses of $10,000.00.
OA6. In a telephone conversation on or about October 21, 2006,
GONZALEZ-DURAN asked MIGUEL TREVINO MORALES for marijuana;
MIGUEL TREVINO MORALES offered GONZALEZ-DURAN 200,000 kilograms; and GONZALEZ-DURAN said that he only wanted 1000 kilograms.
OA7. In a telephone conversation on or about February 6, 2007,
COSTILLA and FLORES BORRGO discussed The Company's successful receipt of
1300 kilograms of cocaine that was to be sent to RAMIREZ-TREVINO in Reynosa,
Mexico.
OA8. In a telephone conversation on or about February 7, 2007, LINO and FLORES BORRGO discussed the arrival of 192 kilograms of cocaine and the loss of 400 kilograms cocaine.
OA9. In a telephone conversation on or about February 8, 2007,
LOPEZ-VALDEZ told GONZALEZ-DURAN that LAZCANO wanted to know what was the price The Company charged for a kilogram of marijuana in Reynosa, Mexico.
GONZALEZ-DURAN replied that they were selling it for between $150 and $170 per kilogram. LO PEZ- VALDEZ asked GONZALEZ-DURAN if that was for the good
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stuff and GONZALEZ-DURAN replied that if it was the good stuff, he could buy it for
$ 1 00 per kilogram and sell it for as much as $ 1 80 or $ 1 90.
OAI0. In a telephone conversation on or about February 10,2007,
COSTILLA and FLORES BORRGO discussed the mode of transportation for 400
kilograms of cocaine, which was to be placed in a hidden compartment concealed within
a gasoline tank.
OAIl. In a telephone conversation on or about February 10,2007,
COSTILLA and FLORES BORRGO discussed imposing a fee of $20,000 per week
for an individual who was transporting marijuana through Reynosa, Mexico, which
FLORES BORRGO described to COSTILLA as "your place."
OAI2. During three telephone conversations on or about February 21,
2007, COSTILLA asked for the name and number of the guy in charge of the plaza at
Nuevo Laredo, Mexico and GONZALEZ-DURAN confirmed to COSTILLA that
MIGUEL TREVINO MORALES was in charge of the plaza at Nuevo Laredo. In the
course of one of the conversations, GONZALEZ-DURAN referred to COSTILLA as
"boss. "
OA13. In a telephone conversation on or about March 1, 2007,
RAMIREZ-TREVINO and FLORES BORRGO discussed in coded language the
seizure of 7000 kilograms of marijuana that were en route to Reynosa, Mexico -
McAllen, Texas border. RAMIREZ-TREVINO stated that the marijuana belonged to
him.
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OAI4. In a telephone conversation on or about March 1, 2007,
RAMlREZ- TREVINO and FLORES BORRGO discussed a pending shipment of
200 kilograms of cocaine to cross from Reynosa, Mexico to McAllen, Texas.
OAI5. In a telephone conversation on or about March 1,2007,
COSTILLA and FLORES BORRGO discussed FLORES BORRGO obtaining contact information for a source of supply of cocaine in Colombia so that they would have better access to multiple kilogram quantities of cocaine. COSTILLA told
FLORES BORREGO that, since 1996, he had worked in Chiapas, which is a Mexican state located on Mexico's southern border with Guatemala.
OA16. In a telephone conversation on or about March 7,2007, REJON
AGUILAR and FLORES BORRGO discussed a parked vehicle that FLORES
BORRGO was having diffculty moving across the border into the United States because of an increased military and law enforcement presence in the area where they usually cross. REJON AGUILAR told FLORES BORRGO that he has a crossing that he uses to cross 70 to 100 kilograms of cocaine at a time and that it is a sure thing.
OA17. In a telephone conversation all or about March 9,2007, LAM-LIU told GONZALEZ-DURAN about an individual with a 400 kilogram shipment of marijuana that LAM-LIU received in Rio Bravo (Mexico). LAM-LIU stated that he would not charge the individual any fees or taxes because the individual was a friend of
LAM-LIU. LAM-LIU fuiiher told GONZALEZ-DURAN that part of the marijuana shipment was going to GONZALEZ-DURAN's area. GONZALEZ-DURAN agreed that the individual should not be charged.
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OA18. In a telephone conversation on or about March 26, 2007, FLORES
BORREGO told MIGUEL TREVINO MORALES that The Company's shipping cost per kilogram for marijuana was twenty dollars. MIGUEL TREVINO MORALES told
FLORES BORRGO to get him some enclosed trucks. MIGUEL TREVINO
MORALES stated to FLORES BORREGO that he has control of the Ministerial Police
throughout the State of Veracruz, Mexico.
OA19. In a telephone conversation on or about March 26, 2007, OMAR
TREVINO MORALES told GONZALEZ-DURAN that OMAR TREVINO
MORALES's people were moving more bulk currency in a grey Chevrolet Avalanche sport utility vehicle with Tamaulipas plates.
OA20. In a telephone conversation on or about April 5,2007,
RAMIREZ-TREVINO and FLORES BORRGO discussed in coded language the seizure in Roma, Texas of kilograms of cocaine which were shipped from Miguel
Aleman, Mexico through Valadeces, Mexico.
GA21. In a telephone conversation on or about April 6, 2007,
GONZALEZ-DURAN asked MEDINA ROJAS whether a certain individual purchased kilograms of cocaine from MEDINA ROJAS. MEDINA ROJAS said he would check into the matter. MEDINA ROJAS then confirmed to GONZALEZ-DURAN that another individual about whom GONZALEZ-DURAN had earlier inquired is not a member of The Company.
GA22. In a telephone conversation on or about April 9, 2007, OMAR
TREVINO MORALES and FLORES BORRGO discussed in coded language whether FLORES BORREGO could provide OMAR TREVINO MORALES with a
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person to move cocaine across the border from Mexico into the United States. OMAR
TREVINO MORALES stated that he had 800 kilograms. OMAR TREVINO
MORALES and FLORES BORREGO further agreed to send the cocaine over the border in increments of250 kilograms. During the conversation, FLORES BORRGO referred to OMAR TREVINO MORALES as "boss."
OA23. In a coded telephone conversation on or about April LO, 2007,
CERDA-GONZALEZ told GONZALEZ-DURAN that GONZALEZ-DURAN stil owed CERDA-GONZALEZ money for some kilograms of cocaine that CERDA-
GONZALEZ gave him in November 2006. . GONZALEZ-DURAN asked CERDA-
GONZALEZ ifhe had forgotten to pick up the money for the cocaine, and CERDA-
GONZALEZ replied that he did pick up the money but it was shoii $55,000.
GONZALEZ-DURAN then told CERDA-GONZLEZ that he would check with his colleagues and check the records, and that he would get the $55,000 to CERDA-
GONZALEZ. After they agreed on resolving the debt matter, CERDA-GONZALEZ told GONZALEZ-DURAN that CERDA-GONZALEZ would deliver thc kilograms of cocaine that GONZALEZ-DURAN ordered on Friday or, at the latest, on Monday.
OA24. In a telephone conversation on or about April 28, 2007, FLORES
BORRGO told COSTILLA that he received a load of cocaine from a Colombian.
COSTILLA and FLORES BORRGO also discussed the seizure of 5000 kilograms of
The Company's cocaine and payment to COSTILLA for a shipment of marijuana.
OA25. In a telephone conversation .on or about May 1, 2007,
CARDENAS-GUILLEN and FLORES BORRGO discussed iii coded language putting together a shipment of 300 kilograms of cocaine sent to McAllen, Texas.
18 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 19 of 28
OA26. In a telephone conversation on or about May 8, 2007, RAMlREZ-
TREVINO and FLORES BORRGO discussed in coded language COSTILLA's
approval and arrangement of a bribe of $2,000,000 to Mexican government offcials.
OA27. In a telephone conversation on or about May 10, 2007,
CARDENAS-GUILLEN and FLORES BORRGO discussed in coded language a co-
conspirator who was arrested with 300 kilograms of cocaine. CARDENAS-GUILLEN
told FLORES BORRGO to look into whether the arrested individual had "an
accident" or robbed them of their cocaine.
OA28. In a telephone conversation on or about May 11,2007,
CARDENAS-GUILLEN confirmed to FLORES BORREGO that the individual
arrested with300 kilograms of cocaine was "an accident." FLORES BORRGO told
CARDENAS-GUILLEN that the individual is "locked up" but might get out on baiL.
OA29. In a coded telephone conversation on or about May 21, 2007,
GONZALEZ-DURAN and MIGUEL TREVINO MORALES discussed a shipment of
300 to 400 kilograms of cocaine that NAJERA-TALAMANTES was transporting to
GONZALEZ-DURAN from MIGUEL TREVINO MORALES. GONZALEZ-
DURAN agreed to send someone to pick up the cocaine in Rio Bravo, Mexico and transport it to Miguel Aleman, Mexico using a Chevrolet Avalanche sport utility vehicle.
OA30. In a telephone conversation on or about May 23, 2007, LINO and
FLORES BORRGO discussed a fifty-kilogram cocaine order for MEJIA-
GONZALEZ.
19 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 20 of 28
OA31. In a telephone conversation on or about May 29, 2007 with
GONZALEZ-DURAN, LAZCANO used coded language to establish $12,000 as The
Company's selling price for kilograms of cocaine.
OA32. In a telephone conversation on or about May 29, 2007,
GONZALEZ-DURAN told FLORES BORREGO that LAZCANO set the selling price for The Company's cocaine at $12,000 per kilogram.
OA33. In a telephone conversation on or about June 5, 2007,
GONZALEZ-DURAN agreed to buy fifty kilograms of cocaine at a price of $ 1 2,000 per kilograi11 from CERDA-GONZALEZ.
OA34. In a telephone conversation on or about June 6, 2007, MIGUEL
TREVINO MORALES told FLORES BORRGO to transport 400 kilograms of cocaine through Camargo, Mexico into Rio Grande City, Texas. FLORES BORRGO then told MIGUEL TREVINO MORALES that he would move the cocaine across fifty kilograms at a time to keep it safe and cut losses.
OA35. On or about June 7, 2007, LAZCANO, FLORES BORRGO, and others convened a leadership meeting for the purpose ofplaiming and coordinating
The Company's cocaine and marijuana trafficking activities.
OA36. On or about June 8, 2007, COSTILLA and FLORES
BORRGO discussed the seizure, by law enforcement agents in Texas, of approximately
$2,700,000 concealed in a grey Chevrolet Avalanche sport utilty vehicle with
Tamaulipas plates. COSTILLA and FLORES BORRGO specifically discussed a claim by GONZALEZ-DURAN that the seized currency belonged to MIGUEL
TREVINO MORALES.
20 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 21 of 28
OA37. In a telephone conversation on or about June 20, 2007, MIGUEL
TREVINO MORALES told FLORES BORRGO that he wanted him to manage the
transport of a shipment of cocaine into McAllen, Texas.
OA38. In a coded telephone conversation on or about Junè 21,2007,
MEJIA-GONZALEZ told GONZALEZ-DURAN that he received a load of bulk
currency and would conceal it into a hidden compartment of a tractor trailer filled with
produce, which they would transport to Tampico, Mexico. MEJIA-GONZALEZ and
GONZALEZ-DURAN also discussed having Colombian cocaine suppliers visit Mexico
to negotiate payments for bulk shipments of cocaine.
OA39. In a coded telephone conversation on or about June 24,2007,
LOPEZ-VALDEZ asked GONZALEZ-DURAN if LAZCANO spoke to
GONZALEZ-DURAN last night about a supply of marijuana. GONZALEZ-DURAN
said that he heard from OMAR TREVINO MORALES, who said he was going to send
the marijuana to MEJIA-GONZALEZ and FLORES-BORREGO. GONZALEZ-
DURAN also said that he told MEJIA-GONZALEZ and FLORES-BORREGO that he was going to help them transpOli about 2000 kilograms of marijuana. LOPEZ-
VALDEZ told GONZALEZ-DURAN that the marijuana belonged to LAZCANO.
GONZALEZ-DURAN said that if that marijuana belonged to LAZCANO then there
would be no problem and that they would bring it to Reynosa, Mexico, LOPEZ-
VALDEZ repeated that the 2000 kilograms of marijuana belonged to LAZCANO.
OA40. In a telephone conversation on or about June 25, 2007, MEJIA-
GONZALEZ and FLORES BORRGO discussed the payment terms of a pending
shipment of cocaine from Venezuela to Tampico, Mexico.
21 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 22 of 28
OA4L. Beginning on or about June 25,2007, and continuing until October
5,2007, members of The Company, including MIGUEL TREVINO MORALES,
FLORES BORRGO, and MEJIA-GONZALEZ, made logistical preparations in and around Altamira, Mexico and Tampico, Mexico, to receive thousands of kilograms, of cocaine from Colombia, which preparations included obtaining warehouse space.
OA42. In a telephone conversation on or about June 26, 2007, REJON
AGUILAR asked FLORES BORRGO for some marijuana. ,FLORES BORRGO said he has people who get good quality for $150 per kilogram. REJON AGUILAR told
FLORES BORREGO that he has a client who wil purchase 20,000 pounds at once.
OA43. In a telephone conversation on or about June 30, 2007, CANO-
FLORES and MEJIA-GONZALEZ discussed in coded language a deal in which
CANO-FLORES would provide MEJIA-GONZALEZ between 500 to 1000 kilograms of marijuana belonging to The Company at a price of $ 1 50 per kilogram. MEJIA-
GONZALEZ told CANO-FLORES that he would bring the money from Laredo as soon as a military checkpoint moved, which he estimated would be in one hour.
OA44. In a telephone conversation on or about July 10,2007, CANO-
FLORES and FLORES BORRGO discussed in coded language CANO-FLORES's delivery of $2,000 and some marijuana to FLORES BORREGO,
OA45. In a telephone conversation on or about July 24,2007, MIGUEL
TREVINO MORALES ordered GONZALEZ-DURAN to contact an individual and to tell him that only "Company" freight is allowed to pass through Camargo, Mexico.
OA46. In a telephone conversation on or about August 17, 2007,
FLORES BORRGO told CARDENAS-GUILLEN in coded language that he has fifty
22 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 23 of 28
kilograms of cocaine for CARDENAS-GUILLEN in order to lower the account with
CARDENAS-GUILLEN, and that he would pay the rest iii a few more days.
OA47. In a telephone conversation on or about September 23,2007,
CARDENAS-GUILLEN and FLORES BORRGO discussed in coded language the
shipment and sale of 1000 kilograms of marijuana and a pending cocaine shipment.
OA48. On or about October 5, 2007, in Altamira, Mexico and Tampico,
Mexico, and elsewhere in Mexico, members of The Company, including CARDENAS-
GUILLEN, COSTILLA, LAZCANO, MIGUEL TREVINO MORALES, FLORES
BORRGO, RAMIREZ-TREVINO, RANGEL, LINO, MEJIA-GONZALEZ, and
CERDA-GONZALEZ, possessed and distributed approximately 11,700 kilograms of
cocaine, which they intended to ship to the United States.
OA49. In a telephone conversation on or about October 12,2007,
MEJIA-GONZALEZ told FLORES BORRGO, in coded language, that RANGEL was telling everyone that the investors in the cocaine recently seized in Altamira, Mexico had seventy-two hours to pay the money they owed or they would be kiled.
OA50. In a telephone conversation on or about October 13, 2007,
RANGEL and FLORES BORRGO discussed in coded language the terms of a
shipment of 100 kilograms of marijuana to McAllen, Texas.
OA5L. In a telephone conversation on or about November 24, 2007, an
associate of LAZCANO ordered RANGEL to maintain an aircraft or helicopter with a pilot in RANGEL's plaza.
23 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 24 of 28
OA52. In a telephone conversation on or about November 24, 2007, an
associate of LAZCANO and RANGEL discussed RANGEL's delivery of$I,700,000 to
purchase 2500 to 3000 kilograms of marijuana.
OA53. In a telephone conversation on or about November 26,2007 with
an unknown male, RANGEL identified himself as "Commander Chicles" from Miguel
Aleman.
OA54. On or about November 30, 2007, in Colon, Panama, and in
Mexico, defendants COSTILLA, RAMIREZ-TREVINO, FLORES BORRGO,
BARRGAN-BALDERAS, and other members of The Company possessed and
distributed approximately 2400 kilograms of cocaine, which they intended to ship to the
United States.
OA55. In a telephone conversation on or about December 8, 2007,
BARRGAN-BALDERAS and FLORES BORRGO disc1.ssed the recent seizure of
2400 kilograms of The Company's cocaine in Panama and discussed who was responsible for the seizure and how they would recover from the seizure.
OA56. In a telephone conversation on or about February 18, 2008,
BARRGAN-BALDERAS and FLORES BORRGO discussed movement of a fifteen kilogram shipment of cocaine.
OA57. In a telephone conversation on or about February 18,2008,
BARRGAN-BALDERAS and FLORES BORREGO discussed the shipment of fifty kilograms of cocaine through McAllen, Texas to Tennessee, where BARRAGAN-
BALDERAS expected to receive $23,000 per kilogram.
24 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 25 of 28
OA58. In a telephone conversation on or about March 4, 2008,
BARRAGAN-BALDERAS and FLORES BORRGO discussed distribution of 5000
kilograms of marijuana to four individuals, including 1000 kilograms to GONZALEZ-
DURAN. BARRGAN-BALDERAS aiid FLORES BORREGO further discussed
MEJIA":GONZALEZ and another individual assisting in storage of the marijuana.
OA59. On or about January 2007, LAM-LIU met with LAZCANO
in Rio Bravo, Mexico to transact a deal for 100 kilograms of cocaine. During said
meeting, LAZCANO agreed to give LAM-LIU 100 kilograms of cocaine to selL. Under
the agreement, LAM-LIU would import the 100 kilograms of cocaine to Houston, Texas
and sell half for LAZCANO, while sellng half for himself to make a profit on.
OA60. On or about January 2007, during the course of a meeting with
LAM-LIU to transact 100 kilograms of cocaine, LAZCANO contacted PEREZ-
ROJAS via Nextel radio to relay orders to provide said cocaine to LAM-LIU. At the
time, PEREZ-ROJAS was outside of the meeting in a vehicle with LOPEZ-VALDEZ.
PEREZ-ROJAS subsequently informed LAZCANO that there were available kilograms
of cocaine being stored in Valle Hermosa, Mexico. PEREZ-ROJAS and LOPEZ-
VALDEZ subsequently arrived back in Rio Bravo with 100 kilograms of cocaine in a vehicle and delivered them to LAM-LID.
25 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 26 of 28
COUNT TWO DISTRIBUTION OF COCAINE FOR IMPORTATION INTO THE UNITED STATES
On or about October 5, 2007, in Mexico, the defendants, ANTONIO EZEQUIEL
CARDENAS-GUILLEN, a.lea. "Tony Tormenta"; JORGE EDUARDO COSTILLA-
SANCHEZ, a.lea. "El Cos," a.k.a. "Doble X," a.lea. "Dos Equis"; HERIBERTO LAZCANO-
LAZCANO, a.k.a. "Lazca," a.lea. "El Licenciado"; MIGUEL TREVINO MORALES, a.lea.
"40," a.k.a. "Zeta 40," a.k.a. "Cuarenta"; SAMUEL FLORES BORRGO, a.k.a. "Tres," a.k.a.
"Metro Tres"; MARIO RAMIREZ-TREVINO, a.k.a. "Mario Pelon," a.k.a. "X20";
ALFREDO RANGEL BUENDIA, a.k.a. "Chicles"; FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. "Lino"; JUAN REYES MEJIA-GONZALEZ, a.lea. "R-l," a.k.a.
"Kike," a.k.a. "Reyes"; and CARLOS CERDA-GONZALEZ, a.k.a. "Puma," a.k.a. "Carlitos"
did unlawfully, knowingly, and intentionally distribute and cause the distribution of five (5) kilograms or more of a mixture or substance containing a detectable amount of cocaine, a
Schedule II controlled substance, intending and knowing that such cocaine would be unlawfully imported into the United States; all in violation of Title 21, Unitcd States Code, Sections 959 and
Title 18, United States Code, Section 2.
COUNT THREE DISTRIBUTION OF COCAINE FOR IMPORTATION INTO THE UNITED STATES
On or about November 30, 2007, in Panama and in Mexico, the defendants, JORGE
EDUARDO COSTILLA-SANCHEZ, a.k.a. "EI Cos," a.k.a. "Doble X," a.k.a. "Dos Equis";
MARIO RAMIREZ-TREVINO, a.k.a. "Mario Pelon," a.k.a. "X-20"; SAMUEL FLORES
BORRGO, a.k.a. "Tres," a.k.a. "Metro"; and GILBERTO BARRGAN-BALDERAS, a.k.a. "Tocayo" did unlawfully, lmowiiigly, and intentionally distribute and cause the distribution
26 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 27 of 28
of five (5) kilograms or more of a mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance, intending and knowing that such cocaine would be unlawfully imported into the United States; all in violationofTitle 21, United States Code,
Sections 959 and Title 18, United States Code, Section 2.
FORFEITURE ALLEGATION
The violations alleged in Count One, Count Two and Count Three are re-alleged and incorporated by reference herein. As a result of the offenses alleged in Count One, Count Two
and Count Three, the defendants, ANTONIO EZEQUIEL CARDENAS-GUILLEN, a.k.a.
"Tony Tormenta"; JORGE EDUARDO COSTILLA-SANCHEZ, a.k.a. "El Cos," a.k.a.
"Doble X," a.k.a. "Dos Equis"; HERIBERTO LAZCANO-LAZCANO, a.k.a. "Lazca," a.k.a.
"El Licenciado"; MIGUEL TREVINO MORALES, a.k.a. "40," a.k.a. "Zeta 40," a.k.a.
"Cuarenta"; JAIME GONZALEZ-DURAN, a.k.a. "Hummer"; SAMUEL FLORES
BORRGO, a.k.a. "Tres," a.k.a. "Metro Tres"; MARIO RAMIREZ-TREVINO, a.k.a. "Mario
Pelon," a.k.a. "X-20" ALFREDO RANGEL BUENDIA, a.k.a. "Chicles"; FIRST NAME
UNKNOWN, LAST NAME UNKNOWN, a.k.a. "Lino"; GILBERTO BARRAGAN-
BALDERAS, a.k.a. "Tocayo"; JUAN REYES MEJIA-GONZALEZ, a.k.a. "R-l," a.k.a.
"Kike," a.k.a. "Reyes"; OMAR TREVINO MORALES, a.k.a. "42,"; JESUS ENRIQUE
REJON AGUILAR, a.k.a. "Mamito," a.k.a. "Cabellero"; ALFONSO LAM-LIU, a.k.a. "Gordo
Lam"; ELEAZAR MEDINA ROJAS, a.k.a. "El Chelelo"; AURELIO CANO-FLORES, a.k.a.
"Yankee," a.k.a. "Yeyo"; CARLOS CERDA-GONZALEZ, a.k.a. "Puma," a.k.a. "Carlitos";
VICTOR HUGO LOPEZ-VALDEZ, a.k.a. "Jorge Hernandez-Martinez,"a.k.a. "Chiri," a.k.a.
"Chiriquas"; SIGIFREDO NAJERA-TALAMANTES, a.k.a. "Canicon," a.k.a. "Chito,"a.k.a.
27 Case 1:08-cr-00057-CKK Document 27 Filed 11/04/10 Page 28 of 28
"Chito Can," a.k.a. "Chito Canico," a.k.a. "Chito Canicon"; DANIEL PEREZ-ROJAS, a.k.a.,
"Cachetes," a.k.a. "Cacheton," shall forfeit to the United States, pursuant to Title 21, United
States Code, Sections 853 and 970, any and all respective right, title, or interest which such
defendants may have in (1) any and all money and/or property constituting, or derived from any proceeds which such defendants obtained, directly or indirectly, as the result of the violations alleged in Count One, Count Two and Count Three ofthis Indictment and (2) any and all property used, in any maimer or part, to commit, or to facilitate the commission of the violations alleged in Counts One, Two and Three of this Indictment.
If any of said forfeitable property, as a result of any act or omission of the defendants,
(a) cannot be located upon the exercise of due diligence, (b) has been transferred or sold to, or deposited with a third party, (c) has been placed beyond the jurisdiction of the Court, (d) has been substantially diminished in value, or (e) has been commingled with other property which
cannot be subdivided without difficulty, it is the intention of the United States, pursuant to Title
21, United States Code, Section 853(p), to seek forfeiture of any other property ofthe defendants
up to the value of the said property. Criminal forfeiture, in violation of Title 21, United States
Code, Sections 853 and 970.
A TRUE BILL:
FOREPERSON h£_ Arthur . Wyatt, Chie Marlon Cobar, Trial Attorney Narcotic and DangerOl s Drug Section Narcotic and Dangerous Drug Section Criminal Division Criminal Division U.S. Department of Justice U.S. Depaiiment of Justice Washington, D.C. 20530 Washington, D.C. 20530
28